Challenges for the new Education Programme

Nearly BGN 2 billion will be invested by the new Education Programme (2021-2027) in the development of pre-school, school and higher education. The Programme will continue the well-known “system projects” from the previous period (Support for Success, Active Inclusion in Pre-school Education, Education for Tomorrow, Student Practices, etc.), and new Operations are foreseen for which schools, kindergartens, NGOs, Personal Development Support Centres( PDSC), etc. will be able to apply. What are these Operations and what are the main difficulties applicants may face?

The total budget of the Education Programme is BGN 1 887 219 069. Most of the operations to be announced are included in the programme. Many of them have a specific beneficiary, the Ministry of Education and Science, and are a continuation of the major system projects from the last programming period. There is also a new “system project” in the field of vocational education and training. Schools/kindergartens will be able to participate in them by applying under a simplified procedure to the MES-as in previous years. NGOs cannot in practice participate in the MES projects. A strength of systemic projects is that they reach a very large number of schools/kindergartens and therefore children and pupils throughout the country. The weakness (disadvantage) is the practical lack of innovation in the activities implemented.

The grant procedures in the new Education Programme: what are they?

The new Education Programme also includes operations that will be implemented through competitive project selection procedures. They are two types:

1. Competitive selection of projects at national level.
2. Selection of projects at local and/or regional level: this will be done through Local Initiative Groups in rural municipalities (this is the Community Led Local Development approach, which has been implemented in the past years with varying success in many smaller municipalities) or through the innovative ITI approach – Integrated Territorial Investments. In the case of ITIs, projects will be implemented covering more than one municipality, district or areas of nearby districts.

Schools, kindergartens, NGOs, etc. will be eligible to apply under the competitive project selection procedures. Which are these? The listed below will be implemented through competitions at national level:

• A procedure aimed at preventing violence and reducing aggression at schools. The procedure will be open to schools, PDSCs and NGOs that will implement campaigns to improve communication between students, provide psychological support, participation of students in school governance, volunteer initiatives and other activities developing civic and global competences.
• “Promoting intercultural education through science, culture and sport: schools, kindergartens, NGOs and others will be eligible to apply. These projects will include a wide range of activities that are necessary for the effective implementation of intercultural education, including teaching and learning activities involving pupils from schools with a concentration of vulnerable groups and other schools, exchange visits, field trips, ‘’green schools’’, cultural and educational initiatives and many others. A special focus will be to promote partnership and systematic interaction between different types of schools (e.g. Roma and non-Roma schools, rural and urban schools). Another focus will be intensive work with parents.
• “Support for talented students”: schools, NGOs and others can apply for this programme with projects to motivate and prepare students for participation in national and regional competitions, Olympiads. A wide range of activities will be eligible for funding, including training camps, summer academies, additional training and scholarships. The focus of the projects will be those rural and urban schools that have not been active in such competitions and contests. The projects will help motivate and prepare talented children who are undoubtedly being taught in all types of schools.
• Operation “Support for creation and implementation of culture of innovation, innovative kindergartens and schools”: the approved projects will aim to create networks for sharing experiences and resources between kindergartens and schools that are actually innovating. It will be possible to support the creation and implementation of packages of methods and tools to support and encourage all schools to diversify their learning.
• “Activities to support renewal and quality assurance of education workforce by promoting alternative access to teaching and by supporting new teachers and principals” will aim to further develop and expand practices to attract highly qualified professionals from different fields as teachers. The Procedure will also support newly recruited teachers and principals through mentoring programmes and networking to share experiences.

A wider range of operations will be implemented at local and district level through the CLLD and especially the ITI approaches:

• The current “New Chance for Success” project, i.e. adult literacy, will be continued. In addition to degree, stage or grade level courses, it is planned to include knowledge validation and other activities. In the new programming period, adult literacy will be implemented through projects under the ITI approach described above. I.e. schools and partner NGOs will be able to submit projects at regional level reflecting the community specificity. NGO involvement will be linked to campaigns to motivate illiterate adults to join literacy courses, etc.
• “Creating conditions for access to education by overcoming demographic, social and spacial problems”. Under this procedure, schools, NGOs and others will be able to apply for additional training for children and pupils to communicate in a multicultural environment, work with parents (including short-term training for parents, teacher training, provision of textbooks, reference books, tools and materials, etc. It will also be implemented at regional level through the ITI approach.
• “Integrated programmes at municipal level for desegregation and prevention of secondary desegregation” will be implemented through projects of Local Initiative Groups. These will be aimed at promoting learning in ethnically mixed environments, including the organisation of joint activities between segregated and non-segregated schools, campaigns among parents, etc.
• Support for establishing Centers for High Achievements in Vocational Education and Training (VET): the operation will include support for vocational schools and other schools with vocational education. They will be supported to develop school curricula and programmes; implement innovative teaching and learning methods: project-based learning, interdisciplinary approach, internships, apprenticeships, incubators for entrepreneurs, etc. for acquiring high-tech skills; continuing qualification of teachers and lecturers in partnership with business and Universities through conducting “business teaches” formats, master classes with top teachers, business and science academies with outstanding specialists, identification of needs and organization of admissions’ plan in the VTC; application of quality indicator framework and surveys from the graduation tracking mechanism; partnerships with Universities, scientific and research organizations and businesses developing activities in similar fields and orientation of students through joint projects, etc; information and communication activities, vocational competitions, Vocational Skills Week, etc.; support for international cooperation with other VET centres through the use of online learning content platforms, joint training programmes or practices, etc., ensuring synergies with Erasmus+ through complementary support.
• Development of dual training system in VET: the operation will include additional vocational training for students, information campaigns, training of teachers and mentors, career guidance, trial apprenticeships with a focus on digital, green economy, blue growth, industry 5.0 and ISIS.

Over the last decade, dual training has established itself as a successful way of linking vocational education to the needs of business: the number of schools implementing dual training is steadily increasing. The Education Programme plans to support this process and reach a minimum of 358 schools.

• Access to higher education for vulnerable groups, disadvantaged groups and non-teaching staff: this operation will continue a similar one that has been probated in the current programming period. The operation will include training of students in grade 12, motivation campaigns with students and their families to continue in tertiary education and support during study period. The support provided will be used for semester fees, mentoring/tutoring, etc.

In the last programming period, Science for Smart Growth Operational Programme, tried to launch such an operation through a competitive selection of projects at national level and in the new period this will be done at regional level through the ITI approach.

Difficulties of competitive selection procedures: what needs to be done?

What are the main difficulties for schools, NGOs and other potential beneficiaries that would hinder them in applying for and implementing such projects?

The so-called “grant” procedures have the potential for very high added value. If the projects approved under them are prepared and implemented successfully, they can bring innovative things to education. However, in the last two years, the interest of potential beneficiaries in competitions launched by SESGOP has been low and in practice some of the procedures have not been implemented as expected. Main difficulties that have discouraged schools and NGOs from applying need to be urgently addressed if the new Programme is to harness the capacity of all stakeholders in education. The key difficulties are:

• low deposits and need of having own funds: formally co-financing or availability of own funds is not required, but in reality without such funds the project cannot be implemented. Normally, when a project is approved, the school/NGO or other beneficiary receives 20% of funds in advance. The time it takes for the verification of the costs already incurred and their “cashing in” by the managing authority is at least 3 months. (By the way, this period has been shortened and streamlined, until 2-3 years ago the verification time took at least half a year) During this time the project activities cannot stop and own funds are needed. Some of the smaller schools and NGOs do not have available resources, which makes them reluctant to apply.

The municipalities receive support from the Flag Fund, which gives an advance for the implementation of the already approved projects. A similar financial instrument targeting NGOs, schools and other beneficiaries is needed to be considered.

• bureaucratic application and reporting procedures: in practice these have been simplified considerably since introduction of the so-called ‘simplified’ costs, i.e. costs that are cashed in on the basis of a product received (e.g. training provided and certificate issued) rather than on the basis of invoices and other documents. However, the reform has not been fully implemented. For example, applicant organisations are required to provide strong technical documentation on the costs incurred under the so-called ‘state aid’. Thus, beneficiaries need to have considerable human resources to do reporting instead of carrying out activities in the field.

In any case, it is necessary for the managing authority to continue using the system of simplified costs in the new period, maximising the time taken for verification and “cashing in” the costs incurred. There is no need to introduce additional bureaucratic requirements that make beneficiaries deal with ‘paperwork’.

• One, at first side technical issue, makes things complicated – implementation of the deminimis system “Deminimis” or “state aid” system restricts an organisation, company or other potential beneficiary from receiving funding, under any European programme, greater than 391 thousand BGN for 3 years. At European level, this system is only in place for purely economic activities in order not to distort market competition. Unfortunately, since 2015, “deminimis” in Bulgaria is also applied in OP “Human Resources Development” and since 2018 also in SESGOP. The latter is a nonsense, as at European level, activities in the field of education are exempt from state aid. It is inevitable that there is no real market when it comes to motivating vulnerable groups, preventing early marriage, etc. However, managing authorities in Bulgaria also apply ‘deminimis’ to SESGOP. I have repeatedly raised this issue at the Monitoring Commitee of the Programme and the representatives of the European Commission, who are its members, have always expressed the position that the operations under SESGOP, especially those targeting vulnerable groups should be exempted from “deminimis”. However, the Ministry of Education, the Ministry of Finance and other responsible institutions have not yet found the courage to take this step.

As a result, active NGOs cannot participate in the implementation of the Operational Programme once they have won a project under SESGOP or OPHRD. This dooms entire competitive project selection operations to failure. As an example, consider the Adult Literacy 3 operation. Schools or consortia of NGOs and schools had to apply with projects. Since most organisations working in education (not many actually working) had won projects under the “Qualification of pedagogical specialists for work in multicultural environment”, they could not submit projects under the new operation. Many of the schools are keen to provide adult literacy but prefer the lead beneficiary to be an NGO that can take on the burden of project preparation and reporting. So “Adult Literacy 3” was implemented using only half of the planned budget. A few months later, there were almost no applicants for the Operation “Access of vulnerable groups to higher education …”

In any case, the Ministry of Education, the Ministry of Finance and the IAPO must find a way to free education projects from “deminimis”. Such ways have been found in all other EU countries. Exempting from “state aid” activities for which there is no real market is an imperative necessity, if we want the grant procedures under the Education Programme (as well as under the HRDP and a number of other financial instruments) to work.

Compared to the SESGOP, the new Education Programme seeks a significantly more balanced approach between direct MES and grant procedures (at national, regional and local level). It is necessary to removing difficulties that hinder potential beneficiaries in order to be able to implement the planned competitive selection procedures. The latter is necessary to achieve innovative things in education with ESF+ funds.

Deyan Kolev